This Privacy Policy describes how the ValueExchange collects, uses and discloses information, and what choices you have with respect to the information.
This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the ValueExchange, or any other third-party products, services or businesses.
Who we are
The data controller for personal data processed through the Services is The ValueExchange Limited (company number 802019), 19 Baggot Street Lower, Dublin 2, D02 X658, Ireland. Contact: info@thevalueexchange.co.
Group companies. The VX (Canada) Ltd, 70 Keewatin Avenue, Toronto ON M4P1Z8, Canada, is a group company of The ValueExchange. We may share personal data with The VX (Canada) Ltd so that staff in that company can operate, support and improve the Services (for example research delivery, finance and customer support). That intra-group sharing is not the optional website-activity sharing control in Settings → Privacy.
Information We Collect
We are committed to respecting your privacy and recognize your need for appropriate protection and management of any personally identifiable information you share with us. When you interact with us through the Services, we collect certain information from you when you voluntarily provide such information. Such ‘Personal Information’ we collect may include, but is not limited to, a first and last name, country of citizenship, phone number, physical address, email address, company name and position, or other contact information that we may request to comply with regulatory requirements. We may use your email address account to send updates, newsletter or news regarding our services.
How We Disclose and Share Information
We consider your information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties, as set forth below:
For external processing: We provide personal information to our trusted businesses or persons to process it for us, based on our instructions and in compliance with all appropriate confidentiality and security measures. For example, we may use service providers to help us with customer support; or we may use an external software platform for data analysis and reporting.
With Corporate Affiliates: The ValueExchange may share your information with its corporate affiliates, parents and/or subsidiaries.
For legal reasons: We will share personal information outside of the ValueExchange if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Meet any applicable law, regulation, legal process or enforceable governmental request.
- Enforce applicable Terms of Service, including investigation of potential violations.
- Detect, prevent or otherwise address fraud, security or technical issues.
- Protect against harm to the rights, property or safety of the ValueExchange, our users or the public as required or permitted by law.
With Consent: the ValueExchange may share your Information with other groups or for other reasons when we have consent to do so.
We may also disclose aggregated user statistics to current and prospective business partners, and to other third parties for other lawful purposes. For example, we may share aggregated or de-identified information on market trends or survey results in a specific country or market sector.
If the ValueExchange is involved in a merger, acquisition or sale of assets, we’ll continue to ensure the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.
Surveys and benchmarks
When you take a survey or benchmark on our platform, The ValueExchange Limited is the data controller for that survey. A given survey may add or replace details on its own privacy page; where they differ, the in-survey notice for that survey applies.
Email. We use the email address you give in the survey to communicate the status of your response, to send you your individual benchmark results, and to share research findings with you.
Responses. Survey answers are processed in anonymised and aggregated form. We do not disclose personally identifying information in those aggregated results. Limited demographic data (such as job role, sector and country) is collected only to support analytical segmentation. We may share de-identified or aggregated survey results with project sponsors, partners or rights holders, including sponsoring banks.
We may share non-personally identifiable information publicly and with our partners – such as sponsors, partners or rights holders. For example, we share responses to individual survey questions with sponsoring banks: but always with all personally-identifiable data removed.
Sharing your benchmark or identity with project partners. Your individual benchmark (and, where the survey asks, your email) may be shared with the project partners named in that survey unless you opt out using the consent questions in that survey. That choice is collected in the survey itself. It is not the same as the optional website-activity sharing control in Settings → Privacy: turning that switch off does not change a survey opt-out, and opting in there does not share survey answers or scorecards.
Webinars and other event registrations keep their own notices.
Website activity sharing
When you create your account you can choose to share your website activity, and the account details we hold for you (name, email, company and job role), with the project sponsors and partners of the projects you take part in. It is optional, it is off unless you turn it on, and turning it off never blocks your account or your access to any part of VX. You can change it at any time in Settings → Privacy.
What it does not cover. Surveys, benchmarks and webinar registrations keep their own policies, case by case: this control does not grant, refuse or override those shares. Turning it off does not change a survey opt-out, and turning it on does not share survey answers or scorecards.
It is one consent purpose, not a general privacy setting. It does not cover international transfers or who our controller is — a member who never turns it on is still hosted on the infrastructure described under International transfers, below.
International transfers
Some of our service providers and group companies are outside the European Economic Area (EEA). In particular, we host the website and related databases, and we send transactional email, using cloud infrastructure in the United States. We also use payment processing, customer-relationship and survey-administration providers that may process data outside the EEA. Product analytics (PostHog) is hosted in the European Union.
Where we transfer personal data outside the EEA, we do so on the basis of a European Commission adequacy decision where one applies (including, for our Canadian group company, the adequacy decision for commercial organisations subject to PIPEDA), or otherwise on Standard Contractual Clauses. You can ask us for more detail at info@thevalueexchange.co.
This is separate from sharing your website-sourced identity with project sponsors and partners, which happens only if you opt in (Settings → Privacy).
Web Cookies
A “Web Cookie” is a string of information that a website stores on a user’s computer and that the user’s browser provides to the website each time the user uses the site. We may employ cookies and similar technologies to keep track of the pages that users visit and to help increase the usability of our products.
Users who do not wish to have web cookies placed on their computers should set their browsers to refuse cookies before accessing our sites, understanding that certain features may not function properly without cookies. Users who refuse cookies assume responsibility for any loss of functionality.
Our Legal Basis for Handling Your Personal Data
When you provide responses, submit, store, send or receive content to or through our Services, you give the ValueExchange (and those we work with) a worldwide licence to use, host, store, reproduce, modify, create derivative works, communicate, publish, publicly perform, publicly display and distribute such content for the limited purpose of operating, promoting and improving our Services, and developing new ones. This licence continues even if you stop using our Services.
Our automated systems analyse your content (including your survey responses) to provide you with personally relevant insights and data, such as customised search benchmark data and market averages. This analysis occurs as the content is sent, received and when it is stored.
Age Limitation
To the extent prohibited by applicable law, the ValueExchange does not knowingly collect personal information from children under the age of 18. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us at info@thevalueexchange.co and we will take steps to delete such information.
Data Retention
We generally retain personal data for so long as it may be relevant to the purposes identified in this Privacy Policy. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
Your Data Rights and Choices
Individuals located in certain countries have statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may request access to your personal information and seek to update, delete, restrict the use of, or correct this information. You can usually do this using the settings and tools provided in your Services account or by clicking the “unsubscribe” link in our marketing materials.
If you cannot use these tools or have any issues or questions, please contact our customer support at info@thevalueexchange.co for additional access and assistance.
Changes to This Privacy Policy
The ValueExchange may change this Privacy Policy from time to time as laws, regulations and industry standards evolve, or as our business and operations develop. We will post the changes on this page and encourage you to review the Privacy Policy to stay informed.
If you disagree with the changes, please contact us at info@thevalueexchange.co. If no solution can be reached, you should deactivate your Services account.
EU Representative
We have appointed Juksta Pty Ltd as our EU representative (under GDPR Article 27). Our certificate of representation is available here. Please contact Juksta for any GDPR-related data requests.
Contacting Us
Please feel free to contact us at any time if you have questions about this Privacy Policy or the information practices of the Services. You may reach us at info@thevalueexchange.co.